AML (Anti Money Laundering) Policy

General provisions:

This document describes the policy of Bitnex (hereinafter referred to as the Company) on combating money laundering, as well as its involvement in the detection and prevention of any activity related to money laundering, terrorist financing and the possibility of using the Company's products and services for the purpose of money laundering (hereinafter referred to as the AML Policy).

Money laundering is the act of converting money or other monetary instruments derived from illegal activities into money or investments that appear to be legitimate so that their illegal source cannot be traced. Domestic and international laws that apply to Companies whose clients can deposit and withdraw funds from their accounts make it illegal for the Company's partners to knowingly engage in or take part in financial transactions with illegally obtained funds.

The aim of anti-money laundering procedures is to ensure that clients involved in financial transactions involving the Company's website are identified to a reasonable standard, with a minimum set of identification data for law-abiding clients. In accordance with the requirements of international law, the Company has developed an internal policy to combat the financing of terrorism and money laundering. The company carefully monitors suspicious activities and transactions, and promptly reports such activities to the relevant authorities.

In order to minimize the risk of money laundering and terrorist financing, the Company does not accept cash as a deposit under any circumstances and does not make cash payments. The Company reserves the right to refuse to process a transaction at any stage if it is suspected that the transaction is in any way related to money laundering or criminal activity. According to international law, the company does not have the right to inform the client that the relevant authorities have been notified about his suspicious activity.

Identification:

The minimum set of mandatory identification data required to open a live trading account includes:

— full name client;

— registration and financial e-mail;

— address of residence or legal address of the client;

— phone number;

In order to comply with anti-money laundering laws, the Company may require the client to provide two documents proving his identity. The first document the Company may require is an identification document issued by the government of the client's jurisdiction with the client's photograph on it. This can be a passport, a driver's license (for countries where a driver's license is the primary identification document), or a local identity card (except for corporate access cards). The second document that the Company may require is an invoice with the full name of the client and the actual address on it not older than 3 months. This can be a utility bill, bank statement, or any other document confirming the address of the client's residence. In certain cases, the Company may also request notarized copies of documents from the client.

Documents in languages other than English must be translated into English by an official translator; the translation must be printed and signed by the translator and sent along with a copy of the original document with a clear photo of the client on it.

Account replenishment, withdrawal of funds:

The Company requires that during the replenishment operation, the name of the sender of funds fully matches the name specified during account registration (if the payment system provides the name of the sender of funds). Payments from third parties are prohibited.

The Company has the right to require strict adherence to the generally accepted procedure for replenishing and withdrawing funds. Funds can be withdrawn to the same account and in the same way that the deposit was made. When withdrawing funds, the name of the recipient must exactly match the name of the client in the Company's database. If the deposit was made by bank transfer, funds can only be withdrawn by the same bank transfer to the same bank and account from which the deposit was made. If the replenishment was made through an electronic payment system, funds can only be withdrawn by means of an electronic payment to the same system and to the same account from which the replenishment was made. The Company has the right, at its discretion, to transfer funds using the payment details that were used to replenish the trading account.

The company declares that, in order to comply with the AML policy, funds transfers by the company's customers are allowed solely for the purpose of carrying out trading operations aimed at generating profit within the framework of the company's services offered. In the event that the Company has reasonable grounds to believe that the funds transfers are used by the account holder in violation of the law and / or the Company's AML policy, for purposes other than the services offered by the Company, the Company reserves the right to block the trading account, as well as personal account client's account (Trader's Room) to conduct any operations on this account.